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#2266948 - 02/28/22 02:19 PM Part 24 Filings for PWI
Niesey Offline
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Joined: Jan 2022
Posts: 7
We are a national bank regulated by the FDIC - are we required to file the after-the-fact notices with the OCC for our public welfare investments? I'm new to being responsible for these filings and I'm finding it hard to locate anything from the FDIC on these requirements. Not sure if all national banks, regardless of regulator for CRA, are required to report to the OCC or if there are instructions for filing with the FDIC and I'm just not looking in the right place. Any guidance is greatly appreciated!!

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#2266950 - 02/28/22 02:28 PM Re: Part 24 Filings for PWI Niesey
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
We are a national bank regulated by the FDIC

That is not possible, if you are a national bank, you are regulated by the OCC, although you might be insured by the FDIC.

I am not sure what filings you are referring too. I do not think that there are any filing requirements in 12 CFR 24.
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#2266975 - 02/28/22 04:49 PM Re: Part 24 Filings for PWI Niesey
Niesey Offline
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Joined: Jan 2022
Posts: 7
There are filing requirements for Public Welfare Investments that qualify under the Investment Test for CRA. Here's an excerpt from the OCC's website on them: An eligible bank may make most 12 CFR 24 investments without prior notification to, or approval by the OCC if the bank follows the after-the-fact notice procedures described under section 24.5(a). Generally, if an investment meets the public welfare, limited liability, and investment limit requirements, an eligible bank may make the investment and notify the OCC within 10 days after making the investment.

Sorry, I misspoke on the other; for the purposes of CRA, we are regulated and examined by the FDIC as a large institution, but we are listed as a Federal Reserve Nonmember Bank for our charter class.

My question is - are we still required to file these notices for PWIs to the OCC?

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#2266978 - 02/28/22 05:03 PM Re: Part 24 Filings for PWI Niesey
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
we are listed as a Federal Reserve Nonmember Bank for our charter class.

That means that you are a State chartered bank that is not a member of the Federal Reserve and you are not a National Bank and the OCC regulations will not apply to you.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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